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  White House Trial Memorandum Jan. 20, 2020 : The Articles should be Rejected

  Section III: Article I Fails Because the Evidence Disproves House Democrats’ Claims (pp80-106)

III. Article I Fails Because the Evidence Disproves House Democrats ' Claims.

Despite House Democrats ' unprecedented, rigged process, the record they compiled clearly establishes that the President did nothing wrong.

This entire impeachment charade centers on a telephone call that President Trump had with President Zelenskyy of Ukraine on July 25, 2019.
There is no mystery about what happened on that call, because the President has been completely transparent: he released a transcript of the call months ago. And that transcript shows conclusively that the call was perfectly appropriate. Indeed, the person on the other end of the call, President Zelenskyy, has confirmed in multiple public statements that the call was perfectly normal. Before they had even seen the transcript, though, House Democrats concocted all their charges based on distortions peddled by a so-called whistleblower who had no first-hand knowledge of the call. And contrary to their claims, the transcript proves that the President did not seek to use either security assistance or a presidential meeting as leverage to pressure Ukrainians to announce investigations on two subjects:( i) possible Ukrainian interference in the 2016 election; or( ii) an incident in which then-Vice President Biden had forced the dismissal of a Ukrainian anti-corruption prosecutor who reportedly had been investigating a company( Burisma) that paid Biden 's son, Hunter, to sit on its board. The President did not even mention the security assistance on the call, and he invited President Zelenskyy to the White House without any condition whatsoever. When the President released the transcript of the call on September 25, 2019, it cut the legs out from under all of House Democrats ' phony claims about a quid pro quo. That should have ended this entire matter.

Nevertheless, House Democrats forged ahead, determined to gin up some other evidence to prop up their false narrative.
But even their rigged process failed to yield the evidence they wanted. Instead, the record affirmatively refutes House Democrats ' claims. In addition to the transcript, the central fact in this case is this: there are only two people who have made statements on the record who say they spoke directly to the President about the heart of this matter-- Ambassador Gordon Sondland and Senator Ron Johnson. And they both confirmed that the President stated unequivocally that he sought nothing and no quid pro quo of any kind from Ukraine. House Democrats ' claims are built entirely on speculation from witnesses who had no direct knowledge about anything and who never even spoke to the President about this matter.

House Democrats ' charges also rest on the fundamentally mistaken premise that it would have been illegitimate for the President to ask President Zelenskyy about either:( i) Ukrainian interference in the 2016 election or( ii) the Biden-Burisma affair.
That is obviously wrong. Asking another country to examine potential interference in a past U.S. election is always permissible. Similarly, it would not have been improper for the President to ask the Ukrainians about an incident in which Vice President Biden had threatened withholding U.S. loan guarantees to secure the dismissal of a prosecutor when Biden had been operating under, at the very least, the appearance of a serious conflict of interest.

The Evidence Refutes Any Claim That the President Conditioned the Release of Security Assistance on an Announcement of Investigations by Ukraine.

The evidence squarely refutes the made-up claim that the President leveraged security assistance in exchange for Ukraine announcing an investigation into either interference in the 2016 election or the Biden-Burisma affair.

The July 25 Call Transcript Shows the President Did Nothing Wrong.

The most important piece of evidence demonstrating the President 's innocence is the transcript of the President 's July 25 telephone call with President Zelenskyy.
In an unprecedented act of transparency, the President made that transcript public months ago. President Trump did not even mention the security assistance on the call, and he certainly did not make any connection between the assistance and any investigation. Instead, the record shows that he raised two issues that are entirely consistent with both his authority to conduct foreign relations and his longstanding concerns about how the United States spends taxpayers ' money on foreign aid: burden-sharing and corruption.

Burden-sharing has been a consistent theme of the President 's foreign policy, and he raised burden-sharing directly with President Zelenskyy, noting that" Germany does almost nothing for you'' and"[ a] lot of the European countries are the same way.''
President Zelenskyy acknowledged that European countries should be Ukraine 's biggest partner, but they surprisingly were not.

President Trump also raised concerns about corruption.
He first raised these concerns in connection with reports of Ukrainian actions in the 2016 presidential election. Numerous media outlets have reported that Ukrainian officials took steps to influence and interfere in the 2016 election to undermine then-candidate Trump, and three Senate committee chairmen are currently investigating this interference. President Trump raised" this whole situation'' and noted particularly that President Zelenskyy was" surrounding[ him] self with some of the same people.'' President Zelenskyy responded by noting that he had recalled the Ukrainian Ambassador to the United States-- an individual who had sought to influence the U.S. election by authoring an anti-Trump op-ed. As Democrats ' witness Dr. Hill testified, many officials in the State Department and NSC were similarly concerned about individuals surrounding Zelenskyy.

The President also mentioned an incident involving then-Vice President Joe Biden and a corruption investigation involving Burisma.
In that incident, a corruption investigation involving Burisma had reportedly been stopped after Vice President Biden threated to withhold one billion dollars in U.S. loan guarantees unless the Ukrainian government fired a prosecutor. At the time, Vice President Biden 's son, Hunter, was sitting on the Burisma 's board of directors. The fired prosecutor reportedly had been investigating Burisma at the time. In fact, on July 22, 2019-- just days before the July 25 call-- The Washington Post reported that the prosecutor" said he believes his ouster was because of his interest in[ Burisma]'' and"[ h] he remained in his post... he would have questioned Hunter Biden.'' The incident raised important issues for anticorruption efforts in Ukraine, as it raised at least the possibility that a U.S. official may have been involved in derailing a legitimate investigation of a foreign sovereign.

As these examples show, President Trump raised corruption issues with President Zelenskyy.
House Democrats ' claim that he did not address corruption because the incidents he raised were" not part of any official briefing materials or talking points'' is nonsense. President Trump spoke extemporaneously and used specific examples rather than following boilerplate talking points proposed by the NSC. That is the President 's prerogative. He is not bound to raise his concerns with a foreign leader in the terms a staffer placed on a briefing card.

More important, President Zelenskyy has publicly confirmed that he understood President Trump to be talking precisely about corruption.
On the call, President Zelenskyy acknowledged that the incidents President Trump had raised highlighted" the issue of making sure to restore the honesty.'' As President Zelenskyy later explained, he understood President Trump to be saying" we are tired of any corruption things.'' President Zelenskyy explained that his response was essentially,"[ w] e are not corrupt.''

In contrast to the explicit discussions about burden-sharing and corruption, there was no discussion of the paused security assistance on the July 25 call.
To fill that gap, House Democrats seize on President Zelenskyy 's statement that Ukraine was" almost ready to buy more Javelins,'' and President Trump 's subsequent turn of the conversation as he said," I would like you to do us a favor though because our country has been through a lot and Ukraine knows a lot about it.'' According to House Democrats, that sequence alone somehow linked the security assistance to a" favor'' for President Trump relating to" his reelection efforts.'' That is nonsense.

First, President Trump asked President Zelenskyy to" do us a favor,'' and he made clear that" us'' referred to" our country''-- as he put it," because our country has been through a lot.''
Second, nothing in the flow of the conversation suggests that the President was drawing a connection between the Javelin sales and the next topics he turned to. The President was clearly transitioning to a new subject. Third, as Democrats ' own witnesses conceded, Javelins are not part of the security assistance that had been temporarily paused. Accordingly, House Democrats ' assertion that" President Trump froze'' Javelin sales" without explanation'' is demonstrably false. Fourth, the President frequently uses variations of the phrase" do us a favor'' in the context of international diplomacy, and the" favors'' have nothing to do with the President 's personal interests. The President can not be removed from office because House Democrats deliberately misconstrue one of his commonly used phrases.

Notably, multiple government officials were on the July 25 call, and only one of them-- NSC Director for European Affairs Alexander Vindman-- raised any concerns at the time about the substance of it.
His concerns were based primarily on policy disagreements and a misplaced belief that the President of the United States should have deferred to him on matters of foreign relations. Lt. Col. Vindman testified that he had" deep policy concerns'' about Ukraine retaining bipartisan support, but he ultimately conceded that the President-- not a staffer like him-- sets policy.

Mr. Morrison, Lt. Col. Vindman 's supervisor, affirmed that" there was nothing improper that occurred during the call.''
Similarly, National Security Advisor to the Vice President Keith Kellogg said that he" heard nothing wrong or improper on the call.''

President Zelenskyy and Other Senior Ukrainian Officials Confirmed There Was No Quid Pro Quo and No Pressure on Them Concerning Investigations.

The Ukrainian government also made clear that President Trump did not connect security assistance and investigations on the call.
The Ukrainians ' official statement did not reflect any such link, and President Zelenskyy has been crystal clear about this in his public statements. He has explained that he" never talked to the President from the position of a quid pro quo'' and stated that they did not discuss the security assistance on the call at all. Indeed, President Zelenskyy has confirmed several separate times that his communications with President Trump were" good'' and" normal,'' and" no one pushed me.'' The day after the call, President Zelenskyy met with Ambassador Volker, Ambassador Sondland, and Ambassador Taylor in Kyiv. Ambassador Volker reported that the Ukrainians" thought[ the call] went well.'' Likewise, Ambassador Taylor reported that President Zelenskyy stated that he was" happy with the call.'' And Ms. Croft, who met with President Zelenskyy 's chief of staff Andriy Bohdan the day after the call, heard from Bohdan that the call" was a very good call, very positive, they had good chemistry.''

Other high ranking Ukrainian officials confirmed that they never perceived a connection between security assistance and investigations.
Ukrainian Foreign Minister Vadym Prystaiko stated his belief that" there was no pressure,'' he has" never seen a direct link between investigations and security assistance,'' and" there was no clear connection between these events.'' Similarly, when President Zelenskyy 's adviser, Andriy Yermak, was asked if" he had ever felt there was a connection between the U.S. military aid and the requests for investigations,'' he was" adamant'' that"[ w] e never had that feeling'' and"[ w] e did not have the feeling that this aid was connected to any one specific issue.''

President Zelenskyy and Other Senior Ukrainian Officials Did Not Even Know that the Security Assistance Had Been Paused.

House Democrats ' theory is further disproved because the evidence shows that President Zelenskyy and other senior Ukrainian officials did not even know that the aid had been paused until more than a month after the July 25, 2019 call, when the pause was reported in Politico at the end of August.
The Ukrainians could not have been pressured by a pause on the aid they did not even know about.

The uniform and uncontradicted testimony from American officials who actually interacted with President Zelenskyy and other senior Ukrainian officials was that they had no reason to think that Ukraine knew of the pause until more than a month after the July 25 call.
Ambassador Volker testified that he" believe[ s] the Ukrainians became aware of the delay on August 29 and not before.'' Ambassador Taylor agreed that, to the best of his knowledge," nobody in the Ukrainian Government became aware of a hold on military aid until... August 29th.'' Mr. Morrison concurred, testifying that he had" no reason to believe the Ukrainians had any knowledge of the review until August 28, 2019.'' Deputy Assistant Secretary Kent and Ambassador Sondland agreed.

Public statements from high-level Ukrainian officials have confirmed the same point.
For example, adviser to President Zelenskyy Andriy Yermak told Bloomberg that President Zelenskyy and his key advisers learned of the pause only from the Politico article. And then-Foreign Minister Pavlo Klimkin learned of the pause in the aid" by reading a news article,'' and Deputy Minister of Defense Oleh Shevchuk learned" through media reports.''

Further confirmation that the Ukrainians did not know about the pause comes from the fact that the Ukrainians did not raise the security assistance in any of the numerous high-level meetings held over the summer-- something Yermak told Bloomberg they would have done had they known.
President Zelenskyy did not raise the issue in meetings with Ambassador Taylor on either July 26 or August 27. And Volker-- who was in touch with the highest levels of the Ukrainian government-- explained that Ukrainian officials" would confide things'' in him and" would have asked'' if they had any questions about the aid. Things changed, however, within hours of the publication of the Politico article, when Yermak, a top adviser to President Zelenskyy, texted Ambassador Volker to ask about the report.

The House Democrats ' entire theory falls apart because President Zelenskyy and other officials at the highest levels of the Ukrainian government did not even know about the temporary pause until shortly before the President released the security assistance.
As Ambassador Volker said:" I do n't believe... they were aware at the time, so there was no leverage implied.'' These facts alone vindicate the President.

House Democrats Rely Solely on Speculation Built on Hearsay.

House Democrats ' charge is further disproved by the straightforward fact that not a single witness with actual knowledge ever testified that the President suggested any connection between announcing investigations and security assistance.
Assumptions, presumptions, and speculation based on hearsay are all that House Democrats can rely on to spin their tale of a quid pro quo.

House Democrats ' claims are refuted first and foremost by the fact that there are only two people with statements on record who spoke directly with the President about the matter-- and both have confirmed that the President expressly told them there was no connection whatsoever between the security assistance and investigations.
Ambassador Sondland testified that he asked President Trump directly about these issues, and the President explicitly told him that he did not want anything from Ukraine:

I want nothing.

I want nothing.
I want no quid pro quo. Tell Zelensky to do the right thing....

Similarly, Senator Ron Johnson has said that he asked the President" whether there was some kind of arrangement where Ukraine would take some action and the hold would be lifted,'' and the answer was clear and"[ w] ithout hesitation'':"( Expletive deleted)-- No way.
I would never do that.''

Although he did not speak to the President directly, Ambassador Volker also explained that President Trump never linked security assistance to investigations, and the Ukrainians never indicated that they thought there was any connection:

[ Q.] Did the President of the United States ever say to you that he was not going to allow aid from the United States to go to[] Ukraine unless there were investigations into Burisma, the Bidens, or the 2016 elections?

[ A.] No, he did not.

[ Q.] Did the Ukrainians ever tell you that they understood that they would not get a meeting with the President of the United States, a phone call with the President of the United States, military aid or foreign aid from the United States unless they undertook investigations of Burisma, the Bidens, or the 2016 elections?
[ A.] No, they did not.

Against all of that unequivocal testimony, House Democrats base their case entirely on witnesses who offer nothing but speculation.
Worse, it is speculation that traces back to one source: Sondland. Other witnesses repeatedly invoked things that Ambassador Sondland had said in a chain of hearsay that would never be admitted in any court. For example, Chairman Schiff 's leading witness, Ambassador Taylor, acknowledged that, to the extent he thought there was a connection between the security assistance and investigations, his information came entirely from things that Sondland said-- or( worse) second-hand accounts of what Morrison told Taylor that Sondland had said. Similarly, Morrison testified that he" had no reason to believe that the release of the security-sector assistance might be conditioned on a public statement reopening the Burisma investigation until[ his] September 1, 2019, conversation with Ambassador Sondland.''

Sondland, however, testified unequivocally that" the President did not tie aid to investigations.''
Instead, he acknowledged that any link that he had suggested was based entirely on his own speculation, unconnected to any conversation with the President:

[ Q.] What about the aid?
[ Ambassador Volker] says that they were n't tied, that the aid was not tied--

[ A.] And I did n't say they were conclusively tied either.
I said I was presuming it.

[ Q.] Okay.
And so the President never told you they were tied.

[ A.] That is correct.

[ Q.] So your testimony and[ Ambassador Volker 's] testimony is consistent, and the President did not tie aid to investigations.

[ A.] That is correct.

Indeed, Sondland testified that he did" not recall any discussions with the White House on withholding U.S. security assistance from Ukraine in return for assistance with the President 's 2020 reelection campaign.''
And he explained that he" did not know( and still do[ es] not know) when, why, or by whom the aid was suspended,'' so he just" presumed that the aid suspension had become linked to the proposed anti-corruption statement.'' In his public testimony alone, Sondland used variations of" presume,''" assume,''" guess,'' or" speculate'' over thirty times. When asked if he had any" testimony[] that ties President Trump to a scheme to withhold aid from Ukraine in exchange for these investigations,'' he stated that he has nothing"[ o] ther than[ his] own presumption,'' and he conceded that"[ n] o one on this planet told[ him] that Donald Trump was tying aid to investigations.'' House Democrats ' assertion that" President Trump made it clear to Ambassador Sondland-- who conveyed this message to Ambassador Taylor-- that everything was dependent on such an announcement[ of investigations],'' simply misrepresents the testimony.

The Security Assistance Flowed Without Any Statement or Investigation by Ukraine.

The made-up narrative that the security assistance was conditioned on Ukraine taking some action on investigations is further disproved by the straightforward fact that the aid was released on September 11, 2019, without the Ukrainians taking any action on investigations.
President Zelenskyy never made a statement about investigations, nor did anyone else in the Ukrainian government. Instead, the evidence confirms that the decision to release the aid was based on entirely unrelated factors. See infra Part III.B. The paused aid, moreover, was entirely distinct from U.S. sales of Javelin missiles and thus had no effect on the supply of those arms to Ukraine.

President Trump 's Record of Support for Ukraine Is Beyond Reproach.

Part of House Democrats ' baseless charge is that the temporary pause on security assistance somehow" compromised the national security of the United States'' by leaving Ukraine vulnerable to Russian aggression.
The record affirmatively disproves that claim. In fact, Chairman Schiff 's hearings established beyond a doubt that the Trump Administration has been a stronger, more reliable friend to Ukraine than the prior administration. Ambassador Yovanovitch testified that" our policy actually got stronger'' under President Trump, largely because, unlike the Obama administration," this administration made the decision to provide lethal weapons to Ukraine'' to help Ukraine fend off Russian aggression. Yovanovitch explained that" we all felt[ that] was very significant.'' Ambassador Taylor similarly explained that the aid package provided by the Trump Administration was a" substantial improvement'' over the policy of the prior administration, because" this administration provided Javelin antitank weapons,'' which" are serious weapons'' that" will kill Russian tanks.'' Deputy Assistant Secretary Kent agreed that Javelins" are incredibly effective weapons at stopping armored advance, and the Russians are scared of them,'' and Ambassador Volker explained that" President Trump approved each of the decisions made along the way,'' and as a result," America 's policy towards Ukraine strengthened.'' As Senator Johnson has noted, President Trump capitalized on a longstanding congressional authorization that President Obama did not:" In 2015, Congress overwhelmingly authorized$ 300 million of security assistance to Ukraine, of which$ 50 million was to be available only for lethal defensive weaponry. The Obama administration never supplied the authorized lethal defensive weaponry, but President Trump did.''

Thus, any claim that President Trump put the security of Ukraine at risk is flatly incorrect.
The pause on security assistance( which was entirely distinct from the Javelin sales) was lifted by the end of the fiscal year, and the aid flowed to Ukraine without any preconditions. Ambassador Volker testified that the brief pause on releasing the aid was" not significant.'' And Under Secretary of State for Political Affairs David Hale explained that" this[ was] future assistance.... not to keep the army going now,'' disproving the false claim made by House Democrats that the pause caused any harm to Ukraine over the summer. In fact, according to Oleh Shevchuk, the Ukrainian Deputy Minister of Defense who oversaw U.S. aid shipments," the hold came and went so quickly'' that he did not notice any change. B. The Administration Paused Security Assistance Based on Policy Concerns and Released It After the Concerns Were Satisfied.

What the evidence actually shows is that President Trump had legitimate policy concerns about foreign aid.
As Under Secretary Hale explained, foreign aid to all countries was undergoing a systematic review in 2019. As he put it," the administration did not want to take a, sort of, business-as-usual approach to foreign assistance, a feeling that once a country has received a certain assistance package... it 's something that continues forever.'' Dr. Hill confirmed this review and explained that" there had been a directive for whole-scale review of our foreign policy, foreign policy assistance, and the ties between our foreign policy objectives and the assistance. This had been going on actually for many months.''

With regard to Ukraine, witnesses testified that President Trump was concerned about corruption and whether other countries were contributing their share.

Witnesses Testified That President Trump Had Concerns About Corruption in Ukraine.

Contrary to the bald assertion in the House Democrats ' trial brief that"[ b] efore news of former Vice President Biden 's candidacy broke, President Trump showed no interest in corruption in Ukraine,'' multiple witnesses testified that the President has long had concerns about this issue.
Dr. Hill, for instance, testified that she" think[ s] the President has actually quite publicly said that he was very skeptical about corruption in Ukraine. And, in fact, he 's not alone, because everyone has expressed great concerns about corruption in Ukraine.'' Similarly, Ambassador Yovanovitch testified that" we all'' had concerns about corruption in Ukraine and noted that President Trump delivered an anti-corruption message to former Ukraine President Petro Poroshenko in their first meeting in the White House on June 20, 2017. NSC Senior Director Morrison confirmed that he" was aware that the President thought Ukraine had a corruption problem, as did many others familiar with Ukraine.'' And Ms. Croft also heard the President raise the issue of corruption directly with then-President Poroshenko of Ukraine during a bilateral meeting at the United Nations General Assembly in September 2017. She also understood the President 's concern"[ t] hat Ukraine is corrupt'' because she had been" tasked[] and retasked'' by then-National Security Advisor General McMaster" to write[ a] paper to help[ McMaster] make the case to the President'' in connection with prior security assistance.

Concerns about corruption in Ukraine were also entirely justified.
As Dr. Hill affirmed," eliminating corruption in Ukraine was one of, if[ not] the central, goals of U.S. foreign policy'' in Ukraine. Virtually every witness agreed that confronting corruption should be at the forefront of U.S. policy with respect to Ukraine.

The President Had Legitimate Concerns About Foreign Aid Burden Sharing, Including With Regard to Ukraine.

President Trump also has well-documented concerns regarding American taxpayers being forced to cover the cost of foreign aid while other countries refuse to pitch in.
In fact," another factor in the foreign affairs review'' discussed by Under Secretary Hale was" appropriate burden sharing.'' The President 's 2018 Budget discussed this precise issue:

The Budget proposes to reduce or end direct funding for international programs and organizations whose missions do not substantially advance U.S. foreign policy interests.
The Budget also renews attention on the appropriate U.S. share of international spending at the United Nations, at the World Bank, and for many other global issues where the United States currently pays more than its fair share.

Burden-sharing was reemphasized in the President 's 2020 budget when it advocated for reforms that would" prioritize the efficient use of taxpayer dollars and increased burden-sharing to rebalance U.S. contributions to international organizations.''

House Democrats wrongly claim that"[ i] t was not until September... that the hold, for the first time, was attributed to the President 's concern about other countries not contributing more to Ukraine'' and that President Trump" never ordered a review of burden-sharing.''
These assertions are demonstrably false.

Mr. Morrison testified that he was well aware of the President 's" skeptical view'' on foreign aid generally and Ukrainian aid specifically.
He affirmed that the President was" trying to scrutinize[ aid] to make sure the U.S. taxpayers were getting their money 's worth'' and explained that the President" was concerned that the United States seemed to-- to bear the exclusive brunt of security assistance to Ukraine. He wanted to see the Europeans step up and contribute more security assistance.''

There is other evidence as well.
In a June 24 email with the subject line" POTUS follow up,'' a Department of Defense official relayed several questions from a meeting with the President, including" What do other NATO members spend to support Ukraine? '' Moreover, as discussed above, President Trump personally raised the issue of burden-sharing with President Zelenskyy on July 25. Senator Johnson similarly related that the President had shared concerns about burdensharing with him. He recounted an August 31 conversation in which President Trump described discussions he would have with Angela Merkel, Chancellor of Germany. According to Senator Johnson, President Trump explained:" Ron, I talk to Angela and ask her,` Why do n't you fund these things,' and she tells me,` Because we know you will.' We 're schmucks, Ron. We 're schmucks.'' And Ambassador Taylor testified that, when the Vice President met with President Zelenskyy on September 1, the Vice President reiterated that" President Trump wanted the Europeans to do more to support Ukraine.''

President Trump 's burden-sharing concerns were entirely legitimate.
The evidence shows that the United States pays more than its fair share for Ukrainian assistance. As Deputy Assistant Secretary Cooper testified," U.S. contributions[ to Ukraine] are far more significant than any individual country'' and" EU funds tend to be on the economic side,'' rather than for" defense and security.'' Even President Zelenskyy noted in the July 25 call that the Europeans were not helping Ukraine as much as they should and certainly not as much as the United States.

Pauses on Foreign Aid Are Often Necessary and Appropriate. Placing a temporary pause on aid is not unusual. Indeed, the President has often paused, re-evaluated, and even canceled foreign aid programs. For example:

In September 2019, the Administration announced that it was withholding over$ 100 million in aid to Afghanistan over concerns about government corruption.

In August 2019, President Trump announced that the Administration and Seoul were in talks to" substantially'' increase South Korea 's share of the expense of U.S. military support for South Korea.

In June, President Trump cut or paused over$ 550 million in foreign aid to El Salvador, Honduras, and Guatemala because those countries were not fairly sharing the burdens of preventing mass migration to the United States.

In or around June, the Administration temporarily paused$ 105 million in military aid to Lebanon.
The Administration lifted the hold in December, with one official explaining that the Administration" continually reviews and thoroughly evaluates the effectiveness of all United States foreign assistance to ensure that funds go toward activities that further U.S. foreign policy and national security interests.''

In September 2018, the Administration cancelled$ 300 million in military aid to Pakistan because it was not meeting its counter-terrorism obligations.

Indeed, Under Secretary Hale agreed that" aid has been withheld from several countries across the globe for various reasons, and, in some cases, for reasons that are still unknown just in the past year.''
Dr. Hill similarly explained that" there was a freeze put on all kinds of aid and assistance because it was in the process at the time of an awful lot of reviews of foreign assistance.'' She added that, in her experience," stops and starts[ are] sometimes common... with foreign assistance'' and that" OMB[ Office of Management and Budget] holds up dollars all the time,'' including in the past for dollars going to Ukraine. Similarly, Ambassador Volker affirmed that aid gets" held up from time-to-time for a whole assortment of reasons,'' and explained that"[ i] t 's something that had happened in[ his] career in the past.''

The Aid Was Released After the President 's Concerns Were Addressed.

To address President Trump 's concerns about corruption and burden-sharing, a temporary pause was placed on the aid to Ukraine.
Mr. Morrison testified that" OMB represented that... the President was concerned about corruption in Ukraine, and he wanted to make sure that Ukraine was doing enough to manage that corruption.'' And OMB Deputy Associate Director for National Security Mark Sandy testified that he understood the pause to have been a result of the President 's" concerns about the contribution from other countries to Ukraine.''

Over the course of the summer and early September, two series of developments helped address the President 's concerns:

First, President Zelenskyy secured a majority in the Ukrainian parliament and was able to begin reforms under his anti-corruption agenda.
As Mr. Morrison explained, when Zelenskyy was first elected, there was real" concern about whether[ he] would be a genuine reformer'' and" whether he would genuinely try to root out corruption.'' It was also unclear whether President Zelenskyy 's party would" be able to get a workable majority in the Ukrainian Parliament'' to implement the corruption reforms he promised. It was only later in the summer that President 's Zelenskyy 's party won a majority in the Rada-- the Ukrainian parliament. As Mr. Morrison testified, on" the opening day of the[ new] Rada,'' the Ukrainians worked through" an all-night session'' to move forward with concrete reforms. Indeed, Mr. Morrison and Ambassador Bolton were in Kyiv on August 27, and Mr. Morrison" observed that everybody on the Ukrainian side of the table was exhausted, because they had been up for days working on... reform legislation.'' President Zelenskyy" named a new prosecutor general''-- a reform that the NSC was" specifically interested in.'' He also" had his party introduce a spate of legislative reforms, one of which was particularly significant,'' namely," stripping Rada members of their parliamentary immunity.'' Additionally, the High Anti-Corruption Court of Ukraine commenced its work on September 5, 2019.

As a result of these developments, Mr. Morrison affirmed that by Labor Day there had been" definitive developments'' to" demonstrate that President Zelensky was committed to the issues he campaigned on.

Second, the President heard from multiple parties about Ukraine, including trusted advisers.
Senator Johnson has said that he spoke to the President on August 31 urging release of the security assistance. Senator Johnson has stated that the President told him then that, as to releasing the aid,"[ w] e 're reviewing it now, and you 'll probably like my final decision.'' On September 3, 2019, Senators Johnson and Portman, along with other members of the Senate 's bipartisan Ukraine Caucus, wrote to the President concerning the status of the aid, and on September 5 the Chairman and Ranking Member of the House Foreign Affairs Committee followed suit with another letter.

Most significantly, Mr. Morrison testified that the Vice President advised the President that the relationship with Zelenskyy" is one that he could trust.''
The Vice President had met with President Zelenskyy in Warsaw on September 1 and had heard firsthand that the new Ukrainian administration was taking concrete steps to address corruption and burden-sharing. On corruption reform, President Zelenskyy" stated his strong commitment'' and shared" some of the things he had been doing,'' specifically what his party had done in the" 2 or 3 days'' since the new parliament had been seated. Morrison testified that, on burden-sharing," President Zelensky agreed with Vice President Pence that the Europeans should be doing more'' and" related to Vice President Pence conversations he 'd been having with European leaders about getting them to do more.''

Moreover, on September 11, 2019, the President heard directly from Senator Portman.
Mr. Morrison testified that Senator Portman made" the case... to the President that it was the appropriate and prudent thing to do'' to lift the pause on the aid. He testified that the Vice President( who had just returned from Europe on September 6) and Senator Portman thus" convinced the President that the aid should be disbursed immediately''-- and the temporary pause was lifted after the meeting. C. The Evidence Refutes House Democrats ' Claim that President Trump Conditioned a Meeting with President Zelenskyy on Investigations.

Lacking any evidence to show a connection between releasing the security assistance and investigations, House Democrats fall back on the alternative theory that President Trump used a bilateral meeting as leverage to pressure Ukraine to announce investigations.
But no witness with any direct knowledge supported that claim either. It is undisputed that a bilateral presidential-level meeting was scheduled for September 1 in Warsaw and then took place in New York City on September 25, 2019, without Ukraine saying or doing anything related to investigations.

A Presidential Meeting Occurred Without Precondition.

Contrary to House Democrats ' claims, the evidence shows that a bilateral meeting between President Trump and President Zelenskyy was scheduled without any connection to any statement about investigations.

Mr. Morrison-- whose" responsibilities'' included" help[ ing] arrange head of state visits to the White House or other head of state meetings''-- testified that he was trying to schedule a meeting without any restrictions related to investigations.
He testified that he understood that arranging" the White House visit'' was a" do-out'' that" came from the President'' on the July 25 call, and he moved forward with a scheduling proposal. He worked with Ambassador Taylor and the NSC 's Senior Director responsible for visits to" determine dates that would be mutually agreeable to President Trump and President Zelensky.'' But due to competing scheduling requests," it became clear that the earliest opportunity for the two Presidents to meet would be in Warsaw'' at the beginning of September. In other words, Mr. Morrison made it clear that he was trying to schedule the meeting in the ordinary course. He did not say that anyone told him to delay scheduling the meeting until President Zelenskyy had made some announcement about investigations. Instead, he explained that, after the July 25 call, he understood that it was the President 's direction to schedule a visit, and he proceeded to execute that direction.

Ultimately, the notion that a bilateral meeting between President Trump and President Zelenskyy was conditioned on a statement about investigations is refuted by one straightforward fact: a meeting was planned for September 1, 2019 in Warsaw without the Ukrainians saying a word about investigations.
As Ambassador Volker testified, Administration officials were" working on a bilateral meeting to take place in Warsaw on the margins of the commemoration on the beginning of World War II.'' Indeed, by mid-August, U.S. officials expected the meeting to occur, and the Ukrainian government was making preparations. As it turned out, President Trump had to stay in the U.S. because Hurricane Dorian rapidly intensified to a Category 5 hurricane, so he sent the Vice President to Warsaw in his place.

Even that natural disaster did not put off the meeting between the Presidents for long.
They met at the next earliest possible date-- September 25, 2019, on the sidelines of the United Nations General Assembly. President Zelenskyy confirmed that there were no preconditions for this meeting. Nor was there anything unusual about the meeting occurring in New York rather than Washington. As Ambassador Volker verified," these meetings between countries sometimes take a long time to get scheduled'' and"[ i] t sometimes just does n't happen.''

House Democrats can not salvage their claim by arguing that the high-profile meeting in New York City did not count and that only an Oval Office meeting would do.
Dr. Hill explained that what mattered was a bilateral presidential meeting, not the location of the meeting

[ I] t was n't always a White House meeting per se, but definitely a Presidential-level, you know, meeting with Zelensky and the President.
I mean, it could 've taken place in Poland, in Warsaw. It could 've been, you know, a proper bilateral in some other context. But in other words, a White House-level Presidential meeting.

The Ukrainians had such a meeting scheduled for September 1 in Warsaw( until Hurricane Dorian disrupted plans), and the meeting took place on September 25 in New York-- all without anyone making any statement about investigations.

No Witness with Direct Knowledge Testified that President Trump Conditioned a Presidential Meeting on Investigations.

House Democrats ' tale of a supposed quid pro quo involving a presidential meeting is further undermined by the fact that it rests entirely on mere speculation, hearsay, and innuendo.
Not a single witness provided any first-hand evidence that the President ever linked a presidential meeting to announcing investigations.

Once again, House Democrats ' critical witness-- Sondland-- actually destroys their case.
He is the only witness who spoke directly to President Trump on the subject. And Sondland testified that, when he broadly asked the President what he wanted from Ukraine, the President answered unequivocally:" I want nothing. I want no quid pro quo. I just want Zelensky to do the right thing, to do what he ran on.''

Sondland clearly stated that" the President never discussed'' a link between investigations and a White House meeting, and Sondland 's mere presumptions about such a link are not evidence.
As he put it, the most he could do is" repeat... what[ he] heard through Ambassador Volker from Giuliani,'' who, he" presumed,'' spoke to the President on this issue. But Ambassador Volker testified unequivocally that there was no connection between the meeting and investigations: Q. Did President Trump ever withhold a meeting with President Zelensky or delay a meeting with President Zelensky until the Ukrainians committed to investigate the allegations that you just described concerning the 2016 Presidential election?

The answer to the question is no, if you want a yes-or-no answer. But the reason the answer is no is we did have difficulty scheduling a meeting, but there was no linkage like that. Q. You said that you were not aware of any linkage between the delay in the Oval Office meeting between President Trump and President Zelensky and the Ukrainian commitment to investigate the two allegations as you described them, correct?

A. Correct.

Sondland confirmed the same point.
When asked if" the President ever[ told him] personally about any preconditions for anything,'' Sondland responded," No.'' And when asked if the President ever" told[ him] about any preconditions for a White House meeting,'' he again responded,"[ p] ersonally, no.'' No credible testimony has been advanced supporting House Democrats ' claim of a quid pro quo.

D. House Democrats ' Charges Rest on the False Premise that There Could Have Been No Legitimate Purpose To Ask President Zelenskyy About Ukrainian Involvement in the 2016 Election and the Biden-Burisma Affair.

The charges in Article I are further flawed because they rest on the transparently erroneous proposition that it would have been illegitimate for the President to mention two matters to President Zelenskyy:( i) possible Ukrainian interference in the 2016 election; and( ii) an incident in which then-Vice President Biden forced the dismissal of a Ukrainian anti-corruption prosecutor who reportedly had been investigating Burisma.
House Democrats ' characterizations of the President 's conversation are false. Moreover, as House Democrats frame their charges, to prove the element of" corrupt motive'' at the heart of Article I, they must establish( in their own words) that the only reason for raising those matters would have been" to obtain an improper personal political benefit.'' And as they cast their case, any investigation into those matters would have been" bogus'' or a" sham'' because, according to House Democrats, neither investigation would have been" premised on any legitimate national security or foreign policy interest.'' That is obviously incorrect.

It would have been entirely proper for the President to ask President Zelenskyy to find out about any role that Ukraine played in the 2016 presidential election.
Uncovering potential foreign interference in U.S. elections is always a legitimate goal. Similarly, it also would have been proper to ask about an incident in which Vice President Biden actually leveraged the threat of withholding one billion dollars in U.S. loan guarantees to secure the dismissal of a Ukrainian prosecutor who was reportedly investigating Burisma-- at a time when his son, Hunter, was earning vast sums for sitting on Burisma 's board. House Democrats ' own witnesses established ample justification for asking questions about the Biden-Burisma affair, as they acknowledged that Vice President Biden 's conduct raises, at the very least, the appearance of a conflict of interest.

It Was Entirely Appropriate for President Trump To Ask About Possible Ukrainian Interference in the 2016 Election.

House Democrats ' theory that it would have been improper for President Trump to ask President Zelenskyy about any role that Ukraine played in interfering with the 2016 election makes no sense.
Uncovering any form of foreign interference in a U.S. presidential election is squarely a matter of national interest. In this case, moreover, there is abundant information already in the public domain suggesting that Ukrainian officials systematically sought to interfere in the 2016 election to support one candidate: Hillary Clinton.

To give just a few examples, a former Democratic National Committee( DNC) consultant, Alexandra Chalupa, admitted to a reporter that Ukraine 's embassy in the United States was" helpful'' in her efforts to collect dirt on President Trump 's then-campaign manager, Paul Manafort.
As Politico reported," Chalupa said the[ Ukrainian] embassy also worked directly with reporters researching Trump, Manafort and Russia to point them in the right directions.'' A former political officer in that embassy also claimed the Ukrainian government coordinated directly with the DNC to assist the Clinton campaign in advance of the 2016 presidential election. And Nellie Ohr, a former researcher for the firm that hired a foreign spy to produce the Steele Dossier, testified to Congress that Serhiy Leshchenko, then a member of Ukraine 's Parliament, also provided her firm with information as part of the firm 's opposition research on behalf of the DNC and the Clinton Campaign. Even high-ranking Ukrainian government officials played a role. For example, Arsen Avakov, Ukraine 's Minister of Internal Affairs, called then-candidate Trump" an even bigger danger to the US than terrorism.''

At least two news organizations conducted their own investigations and concluded Ukraine 's government sought to interfere in the 2016 election.
In January 2017, Politico concluded that" Ukrainian government officials tried to help Hillary Clinton and undermine Trump by publicly questioning his fitness for office.'' And on the other side of the Atlantic, a separate investigation by The Financial Times confirmed Ukrainian election interference. The newspaper found that opposition to President Trump led" Kiev 's wider political leadership to do something they would never have attempted before: intervene, however indirectly, in a US election.'' These efforts were designed to undermine Trump 's candidacy because, as one member of the Ukrainian parliament put it, the majority of Ukrainian politicians were" on Hillary Clinton 's side.''

Even one of House Democrats ' own witnesses, Dr. Hill, acknowledged that some Ukrainian officials" bet on Hillary Clinton winning the election,'' and so it was" quite evident'' that" they were trying to curry favor with the Clinton campaign,'' including by" trying to collect information... on Mr. Manafort and on other people as well.''

If even a fraction of all this is true, Ukrainian interference in the 2016 election is squarely a matter of national interest.
It is well settled that the United States has a" compelling interest... in limiting the participation of foreign citizens in activities of American democratic selfgovernment, and in thereby preventing foreign influence over the U.S. political process.'' Congress has forbidden foreigners ' involvement in American elections. And President Trump made clear more than a year ago that" the United States will not tolerate any form of foreign meddling in our elections'' during his Administration. Even Chairman Schiff is on record agreeing that the Ukrainian efforts to aid the Clinton campaign described above would be" problematic,'' if true.

A request for Ukraine 's assistance in this case also would have been particularly appropriate because the Department of Justice had already opened a probe on a similar subject matter to examine the origins of foreign interference in the 2016 election that led to the false Russian-collusion allegations against the Trump Campaign.
In May of last year, Attorney General Barr publicly announced that he had appointed U.S. Attorney John Durham to lead a review of the origins and conduct of the Department of Justice 's Russia investigation and targeting of members of the Trump campaign, including any potential wrongdoing. As of October, it was publicly revealed that aspects of the probe had shifted to a criminal investigation. As the White House explained when the President announced measures to ensure cooperation across the federal government with Mr. Durham 's probe, his investigation will" ensure that all Americans learn the truth about the events that occurred, and the actions that were taken, during the last Presidential election and will restore confidence in our public institutions.''

Asking for foreign assistance is also routine.
Such requests for cooperation are common and take many different forms, both formal and informal. Requests can be made pursuant to a Mutual Legal Assistance Treaty, and the U.S. has such a treaty with Ukraine that specifically authorizes requests for cooperation. There can also be informal requests for assistance. Because the President is the Chief Executive and chief law enforcement officer of the federal government-- as well as the" sole organ of the federal government in the field of international relations''-- requesting foreign assistance is well within his ordinary role.

Given the self-evident national interest at stake in identifying any Ukrainian role in the 2016 election, House Democrats resort to distorting the President 's words.
They strain to recast his request to uncover historical truth about the last election as if it were something relevant only for the President 's personal political interest in the next election. Putting words in the President 's mouth, House Democrats pretend that, because the President mentioned a hacked DNC server, he must have been pursuing a claim that Ukraine" rather than Russia'' had interfered in the 2016 election-- and that assertion, they claim, was relevant solely for boosting President Trump 's 2020 presidential campaign. But that convoluted chain of reasoning is hopelessly flawed.

To start, simply asking about any Ukrainian involvement in the 2016 election-- including with respect to hacking a DNC server-- does not imply that Russia did not attempt to interfere with the 2016 election.
It is entirely possible that foreign nationals from more than one country sought to interfere in our election by different means( or coordinated means), and for different reasons. Uncovering all the facts about any interference benefits the United States by laying bare all foreign attempts to meddle in our elections. And if the facts uncovered end up having any influence on the 2020 election, that would not be improper. House Democrats can not place an inquiry into historical facts off limits based on fears that the facts might harm their interests in the next election.

In addition, House Democrats have simply misrepresented President Trump 's words.
The President did not ask narrowly about a DNC server alone, but rather raised a whole collection of issues related to the 2016 election. President Trump introduced the topic by noting that" our country has been through a lot,'' which referred to the entire Mueller investigation and false allegations about the Trump Campaign colluding with Russia. He then broadly expressed interest in" find[ ing] out what happened with this whole situation'' with Ukraine. After mentioning a DNC server, the President made clear that he was casting a wider net as he said that"[ t] here are a lot of things that went on'' and again indicated that he was interested in" the whole situation.'' He then noted his concern that President Zelenskyy was" surrounding[ him] self with some of the same people.'' President Zelenskyy clearly understood this to be a reference to Ukrainian officials who had sought to undermine then-candidate Trump during the campaign, as he responded by immediately noting that he" just recalled our ambassador from[ the] United States.'' That ambassador, of course, had penned a harsh, undiplomatic op-ed criticizing thencandidate Trump, and it had been widely reported that a DNC operative met with Ukrainian embassy officials during the campaign to dig up information detrimental to President Trump 's campaign.

Notably, Democrats have not always believed that asking Ukraine for assistance in uncovering foreign election interference constituted a threat to the Republic.
To the contrary, in 2018, three Democratic Senators-- Senators Menendez, Leahy, and Durbin-- asked Ukraine to cooperate with the Mueller investigation and" strongly encourage[ d]'' then-Prosecutor General Yuriy Lutsenko to" halt any efforts to impede cooperation.'' Not a single Democrat in either house has called for sanctions against them. Nothing that President Trump said went further than the senators ' request, and efforts to claim that it was somehow improper are rank hypocrisy.

It Would Have Been Appropriate for President Trump To Ask President Zelenskyy About the Biden-Burisma Affair.

House Democrats ' theory that there could not have been any legitimate basis for a President of the United States to raise the Biden-Burisma affair with President Zelenskyy is also wrong.
The following facts have been publicly reported:

Burisma is a Ukrainian energy company with a reputation for corruption.
Lt. Col. Vindman called it a" corrupt entity.'' It was founded by a corrupt oligarch, Mykola Zlochevsky, who has been under several investigations for money laundering.

Deputy Assistant Secretary of State Kent testified that Burisma 's reputation was so poor that he dissuaded the United States Agency for International Development( USAID) from co-sponsoring an event with Burisma.
He testified that he did not think co-sponsorship with a company of Burisma 's reputation was" appropriate for the U.S. Government.''

In April 2014, Hunter Biden was recruited to sit on Burisma 's board.
At that time, his father had just been made the" public face of the[ Obama] administration 's handling of Ukraine,'' and Britain 's Serious Fraud Office( SFO) had just recently frozen$ 23 million in accounts linked to Zlochevsky as part of a money-laundering investigation. Zlochesvsky fled Ukraine sometime in 2014.

Hunter Biden had no known qualifications for serving on Burisma 's board of directors, and just two months before joining the board, he had been discharged from the Navy Reserve for testing positive for cocaine on a drug test.
He himself admitted in a televised interview that he would not have gotten the board position" if[ his] last name was n't Biden.''

Nevertheless, Hunter Biden was paid more than board members at energy giants like ConocoPhillips.

Multiple witnesses said it appeared that Burisma hired Hunter Biden for improper reasons.

Hunter 's role on the board raised red flags in several quarters.
Chris Heinz, the stepson of then-Secretary of State John Kerry, severed his business relationship with Hunter, citing Hunter 's" lack of judgment'' in joining the Burisma board as" a major catalyst.''

Contemporaneous press reports openly speculated that Hunter 's role with Burisma might undermine U.S. efforts-- led by his father-- to promote an anti-corruption message in Ukraine.
Indeed, The Washington Post reported that"[ t] he appointment of the vice president 's son to a Ukrainian oil board looks nepotistic at best, nefarious at worst.''

Within the Obama Administration, Hunter 's position caused the special envoy for energy policy, Amos Hochstein, to" raise[] the matter with Biden.''
Deputy Assistant Secretary of State Kent testified that he, too, voiced concerns with Vice President Biden 's office.

In fact, every witness who was asked agreed that Hunter 's role created at least the appearance of a conflict of interest for his father.

On February 2, 2016, the Ukrainian Prosecutor General obtained a court order to seize Zlochevsky 's property.

According to press reports, Vice President Biden then spoke with Ukraine 's President Poroshenko three times by telephone on February 11, 18, and 19, 2016.

Vice President Biden has openly bragged that, around that time, he threatened President Poroshenko that he would withhold one billion dollars in U.S. loan guarantees unless the Ukrainians fired the Prosecutor General who was investigating Burisma.

Deputy Assistant Secretary Kent testified that the Prosecutor General 's removal" became a condition of the loan guarantee.''

On March 29, 2016, Ukraine 's parliament dismissed the Prosecutor General.
In September 2016, a Kiev court cancelled an arrest warrant for Zlochevsky.

In January 2017, Burisma announced that all cases against the company and Zlochevsky had been closed.

On these facts, it would have been wholly appropriate for the President to ask President Zelenskyy about the whole Biden-Burisma affair.
The Vice President of the United States, while operating under an apparent conflict of interest, had possibly used a billion dollars in U.S. loan guarantees to force the dismissal of a prosecutor who may have been pursuing a legitimate corruption investigation. In fact, on July 22, 2019-- just days before the July 25 call-- The Washington Post reported that the fired prosecutor" said he believes his ouster was because of his interest in[ Burisma]'' and"[ h] he remained in his post... he would have questioned Hunter Biden.'' Even if the Vice President 's motives were pure, the possibility that a U.S. official used his position to derail a meritorious investigation made the Biden-Burisma affair a legitimate subject to raise. Indeed, any President would have wanted to make clear both that the United States was not placing any inquiry into the incident off limits and that, in the future, there would be no efforts by U.S. officials do something as" horrible'' as strong-arming Ukraine into dropping corruption investigations while operating under an obvious conflict of interest.

As the transcript shows, President Zelenskyy recognized precisely the point.
He responded to President Trump by noting that"[ t] he issue of the investigation of the case is actually the issue of making sure to restore the honesty[.]''

It is absurd for House Democrats to argue that any reference to the Biden-Burisma affair had no purpose other than damaging the President 's potential political opponent.
The two participants on the call-- the leaders of two sovereign nations-- clearly understood the discussion to advance the U.S. foreign policy interest in ensuring that Ukraine 's new President felt free, in President Zelenskyy 's words, to" restore the honesty'' to corruption investigations.

Moreover, House Democrats ' accusations rest on the false and dangerous premise that Vice President Biden somehow immunized his conduct( and his son 's) from any scrutiny by declaring his run for the presidency.
There is no such rule of law. It certainly was not a rule applied when President Trump was a candidate. His political opponents called for investigations against him and his children almost daily. Nothing in the law requires the government to turn a blind eye to potential wrongdoing based on a person 's status as a candidate for President of the United States. If anything, the possibility that Vice President Biden may ascend to the highest office in the country provides a compelling reason for ensuring that, when he forced Ukraine to fire its Prosecutor General, his family was not corruptly benefitting from his actions.

Importantly, mentioning the whole Biden-Burisma affair would have been entirely justified as long as there was a reasonable basis to think that looking into the matter would advance the public interest.
To defend merely asking a question, the President would not bear any burden of showing that Vice President Biden( or his son) actually committed any wrongdoing.

By contrast, under their own theory of the case, for the House Managers to carry their burden of proving that merely raising the matter was" illegitimate,'' they would have to prove that raising the issue could have no legitimate purpose whatsoever.
Their theory is obviously false. And especially on this record, the House Managers can not possibly carry that burden, because no such definitive proof exists. Nobody, not even House Democrats ' own witnesses, could testify that the Bidens ' conduct did not at least facially raise an appearance of a conflict of interest. And while House Democrats repeatedly insist that any suggestions that Vice President Biden or his son did anything wrong are" debunked conspiracy theories'' and" without merit,'' they lack any evidence to support those bald assertions, because they have steadfastly cut off any real inquiry into the Bidens ' conduct. For example, they have refused to call Hunter Biden to testify. Instead, they have been adamant that Americans must simply accept the diktat that the Bidens ' conduct could not possibly have been part of a course of conduct in which the Office of the Vice President was misused to protect the financial interests of a family member.

The Senate can not accept House Democrats ' mere say-so as proof.
Especially in the context of this wholly partisan impeachment, House Democrats ' assurance of," trust us, there 's nothing to see here,'' is not a permissible foundation for building a case to remove a duly elected President from office-- especially given Chairman Schiff 's track record for making false claims in order to damage the President.
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